This sets out BNP Paribas’ UK policy and approach to conducting its tax affairs and dealing with tax risk.
Our guiding principles
BNP Paribas recognises that it has an obligation to pay all taxes required by law and regulations in each of the jurisdictions in which it operates. The group operates with the highest integrity to comply fully with tax laws and related laws around the world and to maintain a co-operative and professional relationship with all tax authorities.
Our approach to governance
The UK Tax Department is responsible for the bank’s tax affairs across all BNP Paribas activities in the UK and is part of the Corporate and Institutional Bank’s Finance Function. The Head of UK Tax also has a reporting line into the Global Head of Tax, ensuring that our policies and procedures in relation to tax are fully aligned to the group-wide policies and risk control frameworks.
The bank’s UK governance structure ensures that tax is considered in business decisions through participation in relevant governance and change approval committees. In addition, tax issues are reported and considered through relevant committees ultimately responsible for UK territory affairs.
Responsibility for BNP Paribas’s UK tax strategy rests with our UK territory management.
Our approach to tax risk management and controls
Inherent tax risks may arise due to the complexity of our day to day activities and uncertainty around the application of tax law. In complex areas where the tax treatment is unclear or uncertain, we may seek external tax advice.
We actively identify, evaluate and manage tax risk to ensure that the financial exposure is understood and acceptable within an appropriate internal control framework which is aligned to the bank’s permanent control framework.
All tax returns are completed to the highest professional standards and are subject to detailed internal checks and quality assurance reviews in accordance with our procedures and controls. Full disclosures are made in the tax returns to ensure that they are clear and understandable.
Our responsible approach to tax planning
All our tax planning is undertaken in accordance with our guiding principles and our commitment to comply with the UK Code of Practice on Taxation for Banks and its requirement to follow the letter as well as the spirit of the law.
Transparent and professional dealings with HM Revenue & Customs (“HMRC”)
Our tax strategy is aligned with Code of Practice on Taxation for Banks which sets out the principles and behaviours expected of banking groups with regard to UK tax. BNP Paribas unconditionally adopted this code in 2013.
In line with the obligations under the Code, the group engages with HMRC prior to undertaking any transaction where there is significant uncertainty in relation to the interpretation of applicable tax law. The group is committed to maintaining an open and transparent relationship with HMRC achieved through regular dialogue and meetings. As such, where there are uncertainties or material events, we aim to resolve these in a timely manner.
*This strategy was first published in 2017 and relates to all subsequent and current financial years, including 2019.